It’s not the bargaining phase you asshole. It’s looking at the facts of the situation in a realistic light.

Over the last 10 years my average AGI was about 110k. In 2017 I had a 480k windfall in my brokerage account and a few months later in 2018 there was a -920k loss.

Why should I have to pay the full tax and penalties and fees on that 480k when I 1) suffered a sever financial hardship due to wild stock market conditions 2) have lost the means to generate that level of income 3) have no history of ever generating that level of income 4) requiring Me to pay in full will put me in a financial hardship for the next 7-10 years?

All I’m saying is there should be a process to look at extenuating circumstances and make changes that are realistic. Saying I had an agi in 2017 of 650k with ignoring that almost all of it was investment income I can not generate again because of a total loss is irrational. That’s like expecting someone to commute 50 miles to work everyday when their car is broke down and there is no public transportation to where they need to go. Your setting them up for failure and putting them in a position that maybe they will just stop going to work. I could 100% just quit my job and let the statuette of limitations run out on collections.